[NFHS] Is there room for judgement on this

[Nevadaref]

There is no rule which mandates that any foul committed during a throw-in has to be intentional, but it certainly may be called such. Here is the latest guidance from the NFHS on these plays:

2006-07 POINTS OF EMPHASIS
#4
Intentional Fouls. The committee continues to be concerned about how games end. While there has been some improvement in the application of the rule, there is still need for further understanding and enforcement. An intentional foul is a personal or technical foul that neutralizes an opponent's obvious advantageous position. Contact away from the ball or when not making a legitimate attempt to play the ball or player, specifically designed to stop or keep the clock from starting, shall be intentional. Intentional fouls may or may not be premeditated and are not based solely on the severity of the act. A foul also shall be ruled intentional if while playing the ball a player causes excessive contact with an opponent.

Fouling is an accepted coaching strategy late in the game. There is a right way and a wrong way to foul. Coaches must instruct their players in the proper technique for strategic fouling. "Going for the ball" is a common phrase heard, but intentional fouls should still be called on players who go for the ball if it is not done properly.

Additionally, in throw-in situations, fouling a player that is not involved in the play in any way (setting a screen, attempting to receive the in-bound pass, etc. ) must be deemed intentional. Far too often, officials do not call fouls as intentional when the act clearly meets the criteria.